Facts:

The case of Leon Abanilla vs. Pastor Villas, Acting Warden of the Leyte Provincial Jail, arose on March 8, 1931, in San Isidro, Leyte, where Leon Abanilla and two co-accused, Benjamin Garrido and Catalino Gabarda, were charged with theft, specifically concerning a small quantity of corn. The allegations fell squarely within the jurisdiction of the Justice of the Peace court. Initially, the justice of the peace recused himself from the case against Abanilla due to a familial relation within the sixth civil degree but proceeded to adjudicate the cases of Garrido and Gabarda, leading to their conviction. Subsequently, both co-accused appealed their convictions, which ultimately resulted in the dismissal of their case by the Court of First Instance at the request of the provincial fiscal, indicating that their acts were merely a civil liability rather than a crime. Conversely, when the case against Abanilla

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Facts:

Background of the Case

• Leon Abanilla, along with two other individuals (Benjamin Garrido and Catalino Gabarda), was charged with the crime of theft involving a small quantity of corn.
• The theft took place in San Isidro, Leyte, and the case was initially heard by the justice of the peace, a court having proper jurisdiction over the offense.

Proceedings Prior to the Conviction

• The original justice of the peace, who first handled the case, inhibited himself from taking the case against Abanilla due to a familial relation within the sixth civil degree.
• Despite his inhibition, the same justice proceeded to try and convict the two other accused, Garrido and Gabarda.
• The case against Abanilla was later transferred to another justice of the peace, who conducted the trial and subsequently convicted him based partly on the conviction of his co-accused.

Subsequent Legal Developments

• The two co-accused, Garrido and Gabarda, appealed their convictions. In the Court of First Instance, their case was dismissed at the request of the provincial fiscal, on the ground that the acts imputed involved mere civil liability rather than constituting a crime.
• Leon Abanilla, on the other hand, did not effectively pursue an appeal from his conviction, resulting in his continued imprisonment. He is now serving his sentence in the provincial jail.

Filing of Habeas Corpus

• Abanilla filed a petition for a writ of habeas corpus in the Court of First Instance of Leyte, seeking his release from detention.
• After the trial court denied the petition, the petitioner escalated the matter by instituting the present appeal.

Contextual Considerations

• Despite the contrasting outcomes between Abanilla and his co-accused, the case stands on the basis of the legal principle that a person lawfully sentenced by a court of competent jurisdiction must serve his sentence.
• The situation is further compounded by the fact that any potential clemency, such as a pardon from the Chief Executive, was not pursued in a timely manner, and thus the judicial process stands as the final arbiter.

Issue:

Applicability of the Writ of Habeas Corpus

• Whether the writ of habeas corpus can be used as a remedy to secure the release of a person lawfully sentenced by a court of competent jurisdiction.
• Whether the writ may serve as an alternative to a proper appeal in inquiring into the merits of the criminal case.

Jurisdiction and Procedural Intent

• Whether it is proper or just for the petitioner to invoke a habeas corpus petition despite the existence of a valid sentence imposed by a competent court.
• The court’s authority to review the merits of the criminal case under the guise of a habeas corpus petition.

Implications of Disparate Outcomes

• The issue arising from the fact that Abanilla remains imprisoned while his co-accused were discharged on different grounds, and whether this discrepancy can form a basis for relief through habeas corpus.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)